CFPB Clarifies TRID Good-Faith Enforcement

October 1, 2015

ALTA received today a letter from Consumer Financial Protection Bureau (CFPB) Director Richard Cordray. The communication was in response to our continued efforts, along with others in the mortgage and real estate industry, requesting a formal hold-harmless period following implementation of the TILA-RESPA Integrated Disclosures (TRID) regulation on October 3.

In the letter, Director Cordray states that "during initial examinations for compliance with the Rule, the agencies' examiners will evaluate an institution's compliance management system and overall efforts to come into compliance, recognizing the scope and scale of changes necessary for each supervised institution to achieve effective compliance." The Office of the Comptroller of the Currency issued a letter with similar language regarding TRID compliance.

We appreciate Director Cordray once again recognizing the need for a hold-harmless period for companies that make a good-faith effort to comply with the TRID regulation.

However, ALTA will continue to support legislative action, such as H.R. 3192 sponsored by Reps. French Hill (R-Ark.) and Brad Sherman (D-Calif.) that would extend an official hold-harmless period until Feb. 1, 2016. The bill also would provide relief from civil liability. We appreciate House Majority Leader Kevin McCarthy's (R-Calif.) notice of a scheduled vote on this important legislation for mid-next week.

Please contact your ALTA staff if you have any questions.

Contact ALTA at 202-296-3671 or